{"id":2576,"date":"2025-12-01T21:11:32","date_gmt":"2025-12-02T01:11:32","guid":{"rendered":"https:\/\/blogs.duanemorris.com\/classactiondefense\/?p=2576"},"modified":"2025-12-01T21:11:33","modified_gmt":"2025-12-02T01:11:33","slug":"district-of-columbia-federal-court-declines-to-narrow-eeocs-pregnancy-bias-suit-against-security-firm","status":"publish","type":"post","link":"https:\/\/blogs.duanemorris.com\/classactiondefense\/2025\/12\/01\/district-of-columbia-federal-court-declines-to-narrow-eeocs-pregnancy-bias-suit-against-security-firm\/","title":{"rendered":"District Of Columbia Federal Court Declines To Narrow EEOC\u2019s Pregnancy-Bias Suit Against Security Firm"},"content":{"rendered":"
\n
\"\"<\/a><\/figure>\n<\/div>\n\n\n

By Gerald L. Maatman, Jr., Rebecca Bjork, and Anna Sheridan<\/strong><\/p>\n\n\n\n

Key Takeaways:<\/strong> \u00a0In EEOC v. Security Assurance Management Inc., No. 25-CV-00181, 2025 WL 2911781 (D.D.C. Oct. 14, 2025), <\/em>\u00a0Judge Rudolph Contreras of the U.S. District Court for the District of Columbia refused to pare back the EEOC\u2019s pregnancy and lactation claims against Security Assurance Management, Inc. (\u201cSAM\u201d), leaving all five causes of action under the Pregnant Workers Fairness Act (PWFA) and both Title VII counts intact. Applying Rule 12(c), the Court held – in an order denying <\/a>Defendant\u2019s Partial Motion to Dismiss – the \u201cheavy burden\u201d on a defendant seeking judgment on the pleadings and determined that the EEOC\u2019s theories \u2014 though factually overlapping \u2014 targeted distinct harms and therefore were not \u201cduplicative.\u201d The Court\u2019s refusal to dismiss any of the EEOC\u2019s PWFA counts sends a clear signal that defendants will face an uphill battle when trying to narrow pregnancy-related claims at the pleadings stage, particularly after filing an answer.<\/em><\/p>\n\n\n\n

Case Background<\/strong><\/p>\n\n\n\n

The EEOC filed suit under Title VII and the PWFA on behalf of Simone Cooper, a special police officer who was reassigned after the client at her post did not want her working at the site while pregnant. (Compl. \u00b6 17).  As the court summarized, the EEOC \u201cbrings this employment discrimination action against Security Assurance Management, Inc. pursuant to Title VII \u2026 and the Pregnant Workers Fairness Act,\u201d alleging that SAM \u201cdisciplined and removed an employee, Simone Cooper (\u2018Ms. Cooper\u2019), from her assignment due to her pregnancy-related condition and her need for accommodations.\u201d Id<\/em>. at *3.<\/p>\n\n\n\n

After her maternity leave, Cooper was placed at a Hampton Inn post where she \u201cwas breastfeeding and had the pregnancy-related medical condition of lactation.\u201d Id.<\/em> The court noted that she \u201ccould nonetheless perform the essential functions of her job as an Unarmed Special Police Officer,\u201d but SAM \u201crepeatedly denied or ignored Ms. Cooper\u2019s accommodation requests.\u201d Id.<\/em> The consequences were significant, as \u201cMs. Cooper leaked through her clothing during the workday on at least two occasions,\u201d and because SAM provided no adequate space, \u201cMs. Cooper had to pump in her car in the Hampton Inn parking lot.\u201d Id.<\/em><\/p>\n\n\n\n

Despite outreach by Cooper, her union representative, and her attorney, the company allegedly did not engage in any interactive process. SAM eventually issued a written warning for \u201cexcessive absenteeism\u201d that included days she was not scheduled and the day she left after leaking through her uniform. Id. <\/em>at *4. She was later removed from the schedule entirely.<\/p>\n\n\n\n

The complaint asserts seven claims, including two under Title VII and five under the PWFA for failure to accommodate, adverse action based on accommodation requests, denial of employment opportunities, retaliation, and interference. After it filed its Answer, SAM filed a partial motion to dismiss seeking dismissal of three of the counts as purportedly duplicative.<\/p>\n\n\n\n

The Court\u2019s Ruling<\/strong><\/p>\n\n\n\n

Because SAM filed an Answer before seeking dismissal, the court treated the request as a Rule 12(c) motion. As Judge Contreras explained, such a motion \u201cwill be granted only if Defendant can demonstrate that no material fact is in dispute and that it is entitled to judgment as a matter of law,\u201d and at this early stage the movant \u201cshoulders a heavy burden of justification.\u201d Id.<\/em> at *6.<\/p>\n\n\n\n

The Court began with its definition, citing from Wultz v. Islamic Republic of Iran<\/em>\u2019s \u201cduplicative claim test.\u201d It explained that \u201cduplicative claims are those that stem from identical allegations, that are decided under identical legal standards, and for which identical relief is available.\u201d Id.<\/em> at *7 (quoting Wultz<\/em>, 755 F. Supp. 2d 1, 81 (D.D.C. 2010)).  SAM argued that several PWFA claims were repetitive, but after analyzing each count, the Court held otherwise.<\/p>\n\n\n\n

Most notably, SAM asserted that the \u201cAdverse Actions\u201d claim duplicated the PWFA retaliation claim because both concerned similar employment decisions. Judge Contreras disagreed, emphasizing that the counts \u201cassert different motivations for Defendant\u2019s allegedly unlawful conduct.\u201d Id.<\/em> at *8. The adverse-action theory centers on actions taken \u201con account of\u201d Cooper\u2019s accommodation requests, while retaliation requires adverse treatment because she opposed unlawful practices. \u201cBecause Count Two (Adverse Actions) and Count Four (Retaliation) arise from different allegations,\u201d the court concluded, \u201cthe claims are not duplicative.\u201d Id. <\/em>at *9.<\/p>\n\n\n\n

The Court applied the same reasoning to SAM\u2019s attempt to collapse the PWFA adverse-action, denial-of-opportunities, and interference counts into the single failure-to-accommodate claim. Those theories, Judge Contreras explained, each addressed different harms and are evaluated under distinct legal standards. As a result, \u201cnone are duplicative,\u201d and the Court denied the motion in full. Id.<\/em> at* 7.<\/p>\n\n\n\n

Implications For Employers<\/strong><\/p>\n\n\n\n

This opinion is a reminder that overlapping facts do not automatically render multiple statutory claims redundant \u2014 especially under the PWFA, where Congress created several discrete causes of action aimed at different workplace harms. Courts are giving each theory breathing room rather than collapsing them into a single \u201cpregnancy discrimination\u201d count.<\/p>\n\n\n\n

Procedurally, the decision warns defendants against using post-Answer motions to trim suits. Under Rule 12(c), the movant faces a \u201cheavy burden,\u201d and close questions typically favor allowing the case to proceed to discovery.<\/p>\n\n\n\n

Substantively, the facts the Court credited (removing a visibly pregnant worker at a client\u2019s request, ignoring repeated lactation-related accommodation needs, forcing pumping in a car, and disciplining a worker for consequences of inadequate accommodations) are the kinds of scenarios likely to support claims not just under the PWFA, but also under Title VII.<\/p>\n\n\n\n

The decision reinforces that the PWFA is a powerful, stand-alone statute with multiple actionable theories. Courts will not readily prune these claims at the pleading stage, and the EEOC is deploying them aggressively. Employers should treat pregnancy-related accommodation requests with the same rigor as disability accommodations – engage promptly, document communications, provide appropriate space and break time, and avoid client-driven decisions that move or remove pregnant workers.<\/p>\n","protected":false},"excerpt":{"rendered":"

By Gerald L. Maatman, Jr., Rebecca Bjork, and Anna Sheridan Key Takeaways: \u00a0In EEOC v. Security Assurance Management Inc., No. 25-CV-00181, 2025 WL 2911781 (D.D.C. Oct. 14, 2025), \u00a0Judge Rudolph Contreras of the U.S. District Court for the District of Columbia refused to pare back the EEOC\u2019s pregnancy and lactation claims against Security Assurance Management, … <\/p>\n

Continue reading “District Of Columbia Federal Court Declines To Narrow EEOC\u2019s Pregnancy-Bias Suit Against Security Firm”<\/span><\/a><\/p>\n","protected":false},"author":575,"featured_media":0,"comment_status":"closed","ping_status":"closed","sticky":false,"template":"","format":"standard","meta":{"footnotes":""},"categories":[36],"tags":[],"ppma_author":[7,11,133],"class_list":["post-2576","post","type-post","status-publish","format-standard","hentry","category-eeoc-litigation"],"authors":[{"term_id":7,"user_id":575,"is_guest":0,"slug":"gmaatman","display_name":"Gerald L. Maatman, Jr.","avatar_url":"https:\/\/blogs.duanemorris.com\/classactiondefense\/wp-content\/uploads\/sites\/56\/2022\/09\/maatmangerald-100x100.jpg","0":null,"1":"","2":"","3":"","4":"","5":"","6":"","7":"","8":""},{"term_id":11,"user_id":579,"is_guest":0,"slug":"rsbjork","display_name":"Rebecca S. Bjork","avatar_url":"https:\/\/blogs.duanemorris.com\/classactiondefense\/wp-content\/uploads\/sites\/56\/2022\/09\/bjorkrebecca-100x100.jpg","0":null,"1":"","2":"","3":"","4":"","5":"","6":"","7":"","8":""},{"term_id":133,"user_id":711,"is_guest":0,"slug":"asheridan","display_name":"Anna Sheridan","avatar_url":"https:\/\/blogs.duanemorris.com\/classactiondefense\/wp-content\/uploads\/sites\/56\/2025\/04\/sheridananna-100x100.jpg","0":null,"1":"","2":"","3":"","4":"","5":"","6":"","7":"","8":""}],"_links":{"self":[{"href":"https:\/\/blogs.duanemorris.com\/classactiondefense\/wp-json\/wp\/v2\/posts\/2576","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/blogs.duanemorris.com\/classactiondefense\/wp-json\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/blogs.duanemorris.com\/classactiondefense\/wp-json\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/blogs.duanemorris.com\/classactiondefense\/wp-json\/wp\/v2\/users\/575"}],"replies":[{"embeddable":true,"href":"https:\/\/blogs.duanemorris.com\/classactiondefense\/wp-json\/wp\/v2\/comments?post=2576"}],"version-history":[{"count":0,"href":"https:\/\/blogs.duanemorris.com\/classactiondefense\/wp-json\/wp\/v2\/posts\/2576\/revisions"}],"wp:attachment":[{"href":"https:\/\/blogs.duanemorris.com\/classactiondefense\/wp-json\/wp\/v2\/media?parent=2576"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/blogs.duanemorris.com\/classactiondefense\/wp-json\/wp\/v2\/categories?post=2576"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/blogs.duanemorris.com\/classactiondefense\/wp-json\/wp\/v2\/tags?post=2576"},{"taxonomy":"author","embeddable":true,"href":"https:\/\/blogs.duanemorris.com\/classactiondefense\/wp-json\/wp\/v2\/ppma_author?post=2576"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}